Health CommitteeWritten evidence from the British Beer & Pub Association (GAS 07)

The BBPA is the leading trade association for the brewing and pub sector. Our members represent around 95% of all beer brewed in the UK, and own over half the country’s pubs.

Introduction

1. Alcohol consumption and most measures of problem drinking have been in decline over the last five or six years.

2. Health outcomes have not responded to changes in consumption, questioning the effectiveness of population-level policy interventions.

3. Government policy should focus on tackling alcohol-related harm, rather than aiming to reduce total alcohol consumption.

4. The brewing and pub sectors take responsibility extremely seriously.

5. Brewers and pub owners have fully engaged with the Public Health Responsibility Deal (PHRD), leading to tangible and immediate benefits for consumers.

6. Brewers and pub owners have demonstrated leadership in many areas, in particular alcohol labelling, innovation in lower-strength products and reducing product strengths, supporting consumer information campaigns and providing unit information in pubs.

7. Our members have differing views on minimum pricing. The evidence to suggest that minimum pricing will improve public health or reduce binge drinking is inconclusive at best.

8. The marketing of alcohol in the UK is covered by a very strong self-regulatory system, and further regulation in this area would not be a necessary or proportionate response.

9. Voluntary measures, with Government and industry working together, have proved successful and should be continued and enhanced.

10. The brewing and pub industries contribute significantly to the UK economy, adding nearly £20 billion to the UK economy. The sector contributes over £11 billion in taxation to the Treasury and support almost one million jobs.1

11. The sector employs 1 in 12 of all working, young adults.

Alcohol Consumption and Harm in the UK

12. Based on HMRC alcohol “clearances”, consumption per capita has fallen by 13% since 2004. Alcohol consumption in the UK is currently just below the European average, with Britons drinking less than the French, Germans and Spanish, amongst others.2

13. However, many commentators observe that the pattern of alcohol consumption is key to addressing alcohol-related harm. The trends in those consuming more than double the recommended “regular” daily intake3 have been downwards for a number of years. Since 2005, the proportion of men drinking more than eight units on their heaviest drinking day in a week fell from 23% to 19% in 2010. The percentage of women drinking more than six units on their heaviest drinking day was 15% in 2005 and 13% in 2010.4

14. Drinking at “harmful” levels has also fallen significantly. The proportion of men drinking more than 50 units a week fell from 9% in 2005 to 6% in 2010. For women the proportion drinking more than 35 units a week has fallen from 5% in 2005 to 3% in 2010.5

15. The decline in 16 to 24 year olds consuming double the daily guidelines within the last week has been even more significant. Since 2005, for young men this has fallen from 32 to 24% and for young women from 27 to 17%.6

16. The proportion of young people (11 to 15 year olds) who have tried alcohol has fallen from 59% in 2004, to 45 in 2010 (England only).7

17. The review in the methodology for has reduced the headline figure quoted for alcohol-related admissions. The primary diagnosis method shows that the number of hospital admissions attributed to alcohol consumption increased faster than total admissions between 2002–03 and 2005–06 (23% vs 11%), but has increased at a slower rate in the last four years (12% vs 15%) (England only). Alcohol-related admissions make up just over one% of all hospital admissions.8

18. The primary diagnosis method is a more realistic way to measure alcohol-related admissions.

19. Alcohol-related violent crime has fallen by 40% since 1995, and by 11% since 2004–05.9

Responsibility for Alcohol Policy Across Government(s)

20. There is little co-ordinated policy for beer and pubs across Government departments. Beer is predominantly brewed from UK-produced agricultural produce and therefore responsible to DEFRA. Pubs are a central part of the country’s tourism offering and responsible to DCMS, whilst licensing is the responsibility of the Home Office. The Department of Health clearly has a major role to play in alcohol policy, particularly as the service provider for those who suffer from alcohol-related harm. More support for the industry from BIS would be welcome.

21. The BBPA respects the democratic and legal rights of the devolved Parliaments to implement policies that suit the needs of their populations. We therefore appreciate that in certain circumstances policies will vary across jurisdictions. However, where possible, policy should be consistent, particularly around product labelling.

The Role of the Alcohol Industry in Addressing Alcohol-Related Health Problems

22. BBPA believes the industry has a key role in addressing alcohol-related harms. Our members have an inherent interest in the responsible consumption of their products and believe that beer is there to be enjoyed and pubs are the home of sociable and responsible drinking. Industry expertise can be harnessed, as is being demonstrated through the PHRD and campaigns such as “Why Let The Good Times Go Bad?” to ensure the right consumer reach to raise awareness, encourage a responsible attitude to alcohol and provide the information to make informed decisions.

23. The brewing and pub industry has been fully engaged in the Department of Health’s PHRD throughout. The largest members of the Association have signed up to all relevant pledges.

24. Approximately 90% of packaged beer now produced carries the core alcohol messaging.10 Pubs display unit awareness literature in premises, on websites and through social media. These are examples of voluntary agreements which are implemented quickly and are far more effective than legislation.

25. The brewing industry has embraced the opportunity offered by the Treasury’s decision to cut excise duty on beers of 2.8% abv or below. In excess of 20 new brands have been brought to market, supported by significant innovation and investment in marketing. The industry believes this threshold could be increased to 3.5% abv through negotiation with the European Union.

26. Brewers and pub owners have also invested significant resources into Drinkaware as part of a programme to “increase awareness and understanding of the role of alcohol in society, encouraging individuals to make informed choices about their drinking.” BBPA members contribute over £2 million per year to Drinkaware and significantly more through in-kind contributions.

27. BBPA’s biggest producer members are also members of the Portman Group, which has played a leading role in developing industry self-regulation. Their Code of Practice places restrictions on the marketing of alcohol products, and provides an advisory service. The Portman Group was also one of the first organisations to recognise the need for self-regulation through digital media and introduced comprehensive digital marketing guidelines in 2009. They have been regulating online marketing in the UK since 2003.

28. This combines with the Advertising Standards Authority rules on paid-for advertising. This regime is regarded as one of the strictest anywhere in the world.

The Evidence Base For, and Economic Impact Of, Introducing a Fixed Price Per Unit of Alcohol of 40p

29. The BBPA’s membership has a range of views on the subject of minimum pricing.

30. Whilst there is clearly a relationship between alcohol pricing and alcohol consumption, evidence of a link between pricing and harmful consumption is less well established. Are the heaviest drinkers affected by increased prices? The Sheffield study, in line with most international evidence, found that the heaviest drinkers are least responsive to changes in price.11

31. The BBPA believes that it is important that alcohol should be retailed in a manner that is socially responsible and supports a ban on below-cost selling. BBPA supports measures targeted to help those who misuse alcohol, alongside education, awareness, and a tax system that encourages consumers towards lower-strength drinks like beer. Whilst minimum pricing might cut the differential between the price of beer in a supermarket or pub, it must not be seen as the answer to pub closures which are clearly down to high taxation. Minimum pricing is, by definition, a blunt tool and clearly the higher the minimum price the greater the impact on the vast majority who enjoy alcohol responsibly; particularly those on the lowest incomes.

32. Minimum pricing may be a breach of European competition law. BBPA has a real concern that a minimum price would ultimately be achieved through, or result in, higher beer taxation. Beer taxation would have to rise by 80% to achieve the same effect as minimum pricing, damaging both brewers and community pubs, costing tens of thousands of jobs. UK consumers already endure the second highest beer tax rate in Europe, paying 40% of the total tax bill, with a rate that is an astonishing 11 times higher than in the largest beer market, Germany.

33. The key piece of research, from Sheffield University (ScHARR),12 on which the policy of minimum pricing is based is inconclusive on the impact it would have on alcohol-related harm. For example, the latest research suggests that harmful drinkers consume over 70 units per week on average, which will be reduced by less than 3 units per week13 (based on a 45p minimum price).

34. The reduction in health harms claimed in the ScHARR research at 40 pence per unit is based on reductions in consumption. For example, ScHARR suggests a minimum price would lead to a 2.4% fall in consumption in alcohol, and therefore 7,481 fewer alcohol admissions in the first year. Alcohol consumption actually fell by more than double that amount (−6.1%), but alcohol-related hospital admissions increased by 9,000 in 2009.14

35. The level of the minimum unit price will be consulted upon and as well as considering the proportionality and effectiveness, Government needs to consider any unintended consequences.

36. If minimum unit pricing is to be introduced, the Government needs to ensure that it is implemented in a fair and reasonable method, minimising the impact on pubs.

The Effects of Marketing on Alcohol Consumption, in Particular in Relation to Children and Young People

37. The UK has some of the tightest restrictions on the marketing of alcohol in the world, particularly designed to avoid exposing children and young people to alcohol advertising. The large decline in youth consumption over the period that self-regulation has been in place serves as proof that alcohol advertising is not encouraging children to consume alcohol.

38. Research into the link between advertising and alcohol consumption remains inconclusive, and many studies have found no correlation. For example, a study by Gerard Hastings at the University of Stirling found no association between awareness of alcohol marketing at age 13 and either the onset of drinking, or the volume of alcohol consumed two years later.

39. Research has consistently shown that the key influence on consumption by young people is parents and peers. Young people (11 to 15 year olds) are more than twice as likely to have tried alcohol if one or more of the people they live with consume alcohol.15

40. Alcohol advertising bans are in place in France and Norway. Neither appears to have been successful in reducing alcohol-related harm. A review of the French ban, conducted by Dr. Alain Rigaud, President of the French National Association for the Prevention of Addiction and Alcoholism concluded that “no effect on alcohol consumption could be established” from it. In Norway, alcohol consumption increased by nearly 30% in a decade after the ban was introduced.

The Impact that Current Levels of Alcohol Consumption will have on the Public’s Health in the Longer Term

41. Most indicators of harmful consumption are in decline. Furthermore total consumption in the UK remains at or below the levels of our European neighbours.

42. There is also no direct correlation between per capita alcohol consumption and levels of alcohol-related harm across Europe. There are clearly other factors at play, such as patterns of consumption, income levels and wider socio-economic factors, dietary habits, prevalence of smoking, culture, etc.

43. The WHO points out that “the relatively small proportion of deaths in western European countries, in spite of the high level of alcohol consumption in these countries, can be explained by the drinking patterns, the age structure, and the beneficial impact of low-risk drinking in these countries”.16

44. There is a need to understand that total population consumption does not necessarily correlate with total population harm.

45. In the UK in recent decades there has been a growth in sales of stronger drinks. Whilst all drinks can be abused, we firmly believe that Government policy should be encouraging the consumption of lower-strength beverages. The ability to become intoxicated quickly and to dangerous levels from drinking average-strength beers is constrained by volume and capacity. This is recognised by the WHO Global Alcohol Strategy.17

Public Health Interventions such as Education and Information

46. Education and information campaigns in the UK, and in other countries, have led to a much greater knowledge amongst consumers. In the UK, the proportion of people who are aware of measuring alcohol consumption in units has increased from 75% in 1998 to 90% in 2009 as a result of education campaigns. This is much higher amongst regular drinkers.18

Reducing the Strength of Alcoholic Beverages

47. The international evidence for the impact of this policy is limited. However this is a policy approved by the WHO in their Global Alcohol Strategy. The pledge under the PHRD to remove one billion units through the reduction of alcohol strengths and promoting lower-strength alternatives was (as far as we are aware) a world first. Other nations, particularly Spain and Australia, have seen considerable growth in their lower-alcohol beer categories when given the appropriate level of support from Government and industry. This market is still constrained by barriers to advertising lower-strength beers. Of course, beer is already relatively lower in strength than other alcohol products, and should therefore be supported by Government policy.

Raising the Legal Drinking Age

48. The age at which individuals are allowed to purchase alcohol in the UK is 18.19 This is broadly consistent with the rest of Europe, and much of the world. Indeed, many countries have a lower legal age of purchase. The BBPA is unaware of any evidence that suggests increasing the legal purchasing age would be a proportionate or effective measure.

Plain Packaging and Marketing Bans

49. There is very little international evidence on the effectiveness of plain packaging on alcohol products, with no examples of this being implemented in any other country. As packaging of alcohol products is unlikely to be a key determinant as to whether, and how much, alcohol is consumed, we do not believe this should be considered as a realistic policy option. This would also be completely disproportionate for alcohol which, unlike tobacco, has potential health benefits when consumed in moderation.

May 2012

1 Oxford Economics, Local impact of the beer and pub sector.

2 HM Revenue & Customs & BBPA.

3 Sometimes used as a proxy for “binge drinking”.

4 ONS, General Lifestyle Survey 2010, Table 2.4.

5 Ibid, Table 2.2.

6 Ibid, Table 2.4.

7 Smoking, Drinking and Drug Use Among Young People in England, Table 3.1.

8 NHS Information Centre, Statistics on Alcohol, England, 2011, Table 4.5.

9 Home Office, Crime in England & Wales, 2009–10, Table 3.20.

10 Unit content, Chief Medical Officers’ daily drinking guidelines and drinking while pregnant advice.

11 University of Sheffield, Modelling alcohol pricing and promotion effects on consumption and harm, p 51.

12 From the School of Health and Related Research (ScHARR).

13 http://www.sheffield.ac.uk/polopoly_fs/1.150021!/file/scotlandupdatejan2012.pdf

14 http://www.nice.org.uk/guidance/index.jsp?action=download&o=45668

15 Smoking, Drinking and Drug Use among Young People, 2010.

16 WHO Global Alcohol Report.

17 http://www.who.int/substance_abuse/activities/gsrhua/en/

18 NHS Information Centre, Statistics on Alcohol: England, 2011, Table 3.1.

19 With the exception of having alcohol bought for you as an accompaniment to food, in the presence of an adult, where the legal age is 16 for the purchase of beer and wine.

Prepared 19th July 2012